Transparency report

Transparency report

METHODOLOGICAL NOTE – DISCLOSURE OF TRANSFERS OF VALUE 
DIATER LABORATORIOS, S.A.

1. DEFINITIONS

Recipients: Includes Healthcare Professionals and Healthcare Organizations that receive Transfers of Value, including retired or deceased healthcare professionals when transfers attributable to the period exist.

Healthcare Professional (HCP): A natural person who may prescribe, dispense, administer, or influence the use of medicinal products for human use. For disclosure purposes, a self-employed HCP is considered a natural person.

Healthcare Organization (HCO): A legal entity that provides healthcare services or groups healthcare professionals, such as hospitals, clinics, foundations, universities, or scientific societies.

Patient Organization: Not applicable.

Types of Transfers of Value: Donations and grants; contributions to training activities or scientific‑professional meetings; service fees; research and development; other unclassified transfers.

Transfer of Value: Any direct or indirect payment or consideration, in cash, in kind, or in any other form, regardless of its purpose.

Direct Transfer of Value: Made directly by DIATER to an identified recipient.

Indirect Transfer of Value: Made by a third party on behalf of DIATER when the recipient can identify the company.

In‑kind Transfers of Value: Goods or services provided without direct monetary consideration. Disclosed as an independent category according to the EFPIA model.

Other Transfers of Value: Those not classified under the previous categories.

Research and Development (R&D): Activities related to preclinical studies, clinical trials, and post‑authorization studies. Disclosure is made in aggregate form in accordance with EFPIA.

Medicinal products for human use: Substances or combinations of substances intended to treat, prevent, or diagnose diseases in humans.

2. SCOPE OF DISCLOSURE / TRANSPARENCY REPORT

Products included: Prescription medicines.

Company: DIATER Laboratorios, S.A., including subsidiaries or affiliated entities. This methodological note applies exclusively to Spain.

Excluded Transfers of Value: Those not covered by the Code of Practice or not related to prescription medicines.

Date of Transfers of Value: Fiscal year from January to December of the reported year.

Direct and indirect Transfers of Value: Both included according to the Code.

In‑kind Transfers of Value: Included in accordance with applicable valuation rules.

Partial participation, cancellation, or reimbursement: The amount effectively attributed is recorded.

Cross‑border activities or collaborations: Included when the recipient carries out their activity in Spain.

Research and Development: Disclosed in aggregate form.

Voluntary Transfers of Value: Not applicable. This section is included in accordance with the EFPIA model.

3. SPECIFIC CONSIDERATIONS

Unique identification code: DIATER uses a unique internal identifier for each HCP and HCO, linking tax data and transfers of value.

Self‑employed Healthcare Professional: Considered a natural person for disclosure purposes.

Contracts lasting more than one year: Amounts are attributed according to the accrual date within the fiscal year.

Country‑specific characteristics: Application of Spanish regulations and the Farmaindustria Code of Practice. Also includes Spanish regulations on data protection and transparency applicable to relationships with HCPs and HCOs.

Review or audit of information: Not applicable. DIATER does not conduct external audits prior to publication, limiting itself to internal consistency checks.

4. PERSONAL DATA PROTECTION – LEGAL BASIS

Request for consent: Consent is not requested for individual disclosure when legitimate interest applies.

Partial consent: Not applicable.

Legal basis: Legitimate interest for the individual disclosure of Transfers of Value to HCPs, in accordance with the AEPD Report dated 22/04/2016. HCPs are informed pursuant to Organic Law 3/2018.

Right to object: The HCP may object when there are justified and legitimate reasons related to their personal situation. DIATER will assess the request and may exclude individual disclosure. The HCP may file a complaint with the AEPD.

DSR rights: Access, rectification, erasure, restriction, portability, and objection. These rights may be exercised by written request or email to DIATER’s official address.

5. INFORMATION COLLECTION TEMPLATE

Publication date: Before 30 June of the year following the reported fiscal year. For multi‑year contracts, attribution is made according to the accrual date corresponding to the fiscal year.

Publication platform: DIATER’s corporate website.

Publication language: Spanish. An English version is recommended in accordance with EFPIA.

Information collection: Data extracted from internal management and accounting systems. Information is categorized according to the EFPIA table.

Transparency Information Document: HCPs sign an information document stating they have been informed of individual disclosure and provide the data required for their identification.

Identification of recipients: HCPs and HCOs are identified through an internal registry linking tax data and transfers of value. The information comes from the Transparency Information Documents signed by HCPs, which allow the creation of a file with the necessary identification data.

Transfers of value to HCPs through HCOs: Identified through an internal registry linking HCPs and HCOs. For scientific activities, the Society with which collaboration took place is included, reflecting the relationship between HCP and HCO.

6. PUBLISHED ECONOMIC‑FINANCIAL INFORMATION

Currency: Euro (EUR).

Taxes included or excluded: Disclosure based on the taxable amount.

Calculation rules: Application of internal accounting criteria and the Code of Practice. In‑kind transfers are valued at actual attributable cost.

7. ADDITIONAL INFORMATION

Reference documents: Farmaindustria Code of Practice; EFPIA Disclosure Code; Self‑Regulation System website.

Additional information: Not applicable. DIATER implements technical measures to prevent the indexing of published information by search engines, limiting its dissemination to the purposes established in the Code.

Legal notice: DIATER uses automated systems and internal procedures to ensure the accuracy of the published information. In case of error, DIATER will correct the information after verification.

Click the continue button to confirm that you have read the methodological note